Vituro Healthis committed to preservingtheprivacyandconfidentialityofyourhealth information which is created and/ormaintained at our clinic. State and federal lawsand regulations requireus to implement policies and procedures to safeguard theprivacyofyourhealth information. This Notice providesyouwith information regardingourprivacypractices andapplies to all ofyourhealth information created and/ormaintained at ourclinic, including anyinformation that we receivefrom otherhealth careproviders or facilities. TheNoticedescribes theways in which wemayuseor discloseyourhealth information and also describesyourrights and ourobligations concerningsuch uses ordisclosures.

Wewill abidebytheterms ofthis Notice, includinganyfuturerevisions that wemaymaketo the Notice as required orauthorized bylaw. Wereservethe right to changethis Notice and to makethe revised or changedNotice effective forhealth information we alreadyhaveaboutyouas well as any information we receivein the future. Wewill post a copyofthe current notice, which will identifyits effectivedatein ourclinic.

Theprivacypractices described in this Noticewill be followed by:

1. Anyhealth careprofessional authorized to enterinformation intoyourmedical record created and/ormaintained at ourclinic;

2. All employees, students, residents, and otherserviceproviders who have access toyourhealth information at our clinic;and

3. Anymemberofavolunteergroupwhich is allowed to helpyouwhile receivingservices at our clinic.

Theindividuals identified abovewill shareyourhealth information with each other forpurposes of treatment, payment and health careoperations, as furtherdescribed in theNotice

For example, wemayorderaspecialized lab test to betterdiagnoseyourhealth issue and to facilitatethedevelopment ofatreatment plan. In that case, wewill need totalk with the physiciansat thelab so that wecan fullyunderstand thelab results and develop aplan ofcare. We also mayneed to referyou to anotherhealth careprovidertoreceivecertain services. We will shareinformation with that health careproviderin ordertocoordinateyourcare and services.

b. Payment. As wedo notbill insurance companies,this section does not applyforthemost part, but wehaveleft it for completeness. Wemayuseordiscloseyourhealth information so that

wemaybill and receivepayment fromyou, an insurancecompany, oranotherthird partyfor thehealth careservicesyou receive from us. Wealso maydisclosehealthinformation about you toyourhealth plan in orderto obtain priorapproval fortheservicesweprovidetoyou, or to determinethatyourhealth plan will payforthetreatment.

Wemayuseordiscloseyourhealth information in certain special situations as described below. For thesesituations,you havethe right to limit theseuses and disclosures as provided forin Section Fof this Notice.

3. Family Members andFriends. Wemaydiscloseyourhealth information to individuals, such as familymembers and friends, who areinvolved inyourcareorwho help payforyourcare. We maymakesuch disclosures when: (a)wehaveyourverbalagreement to do so; (b)wemakesuch disclosures andyou do not object; or (c)wecan inferfrom the circumstances thatyou would not object to such disclosures. For example, ifyourspouse comes into the exam room withyou, we

will assumethatyou agreeto ourdisclosureofyourinformation whileyourspouseis present in the room.

We also maydiscloseyourhealth information to familymembers or friends in instances whenyou areunableto agreeorobject to such disclosures, provided that wefeel it is inyourbest interests to makesuch disclosuresand thedisclosures relateto that familymemberorfriend’s involvement in yourcare. For example, ifyou present to our clinicwith an emergencymedical condition, wemay shareinformation with the familymemberorfriend that comes withyou toour clinic. We also mayshareyourhealth information with a familymemberorfriend whocalls us to request a prescription refill foryou.

Except forthepurposes identified abovein Sections Bthrough D, wewill not useordiscloseyour health information foranyotherpurposes unlesswehaveyourspecificwritten authorization. You havethe right to revokeawritten authorization at anytimeas long asyou do so in writing. Ifyou revokeyourauthorization, wewill no longeruseordiscloseyourhealth information forthepurposes identified in the authorization, except to the extent that wehavealreadytaken some action in reliance uponyourauthorization.

F. YOUR RIGHTSREGARDING YOUR HEALTH INFORMATION.

You havethefollowingrights regardingyourhealth information. You mayexercise each ofthese rights, in writing, byprovidingus with a completed form thatyou can obtain byemail request to info@viturohealth.comor from ourweb site (follow theprivacylink). In someinstances, wemay chargeyouforthecost(s)associated with providingyou with therequestedinformation. Additional information regardinghow to exerciseyour rights,and the associated costs,can beobtained from Conor Gallagher,ourHIPAAPrivacyOfficial.

1. Right to InspectandCopy. You havethe right to inspect and copyhealth information that may beused to makedecisions aboutyourcare. Wemaydeny yourrequest to inspect and copy your health information in certain limited circumstances. Ifyou aredeniedaccess toyourhealth information,you mayrequest that thedenial bereviewed.

2. Right to Amend. You havethe right to request an amendment ofyourhealth information that is maintained byor forourclinic and is used to makehealth caredecisions aboutyou. Wemaydeny yourrequest ifit is not properlysubmitted ordoesnot includea reason to supportyourrequest.

Wemayalso deny yourrequest iftheinformationsought to be amended: (a)was not created by us, unless theperson orentitythat created theinformation is no longeravailableto makethe amendment; (b)is not part oftheinformation thatis kept byorforourclinic; (c)is not part ofthe information whichyou arepermitted to inspect and copy; or (d)is accurateand complete.

3. Right to anAccounting ofDisclosures. You havethe right to request anaccountingofthe disclosures ofyourhealth information madebyus. This accounting will not includedisclosures of

4. Right to RequestRestrictions. You havetheright to request a restriction orlimitation on the health information weuseordisclose aboutyou fortreatment, payment, orhealth careoperations. You also havetheright to request alimit on thehealth information wedisclose aboutyou to someone, such asa familymemberorfriend, whois involved inyourcareorin thepayment of yourcare. For example, you couldask that wenot useordiscloseinformation regardinga particulartreatment thatyou received. We arenot required to agreetoyour request. Ifwedo agree, that agreement must bein writingand signed by you and us.

5. Right to RequestConfidential Communications. You havethe right to request that we communicatewithyou aboutyourhealth carein acertain wayor ata certain location. For example,you can ask that weonlycontactyou atwork orbymail.

6. Right to a PaperCopyofthis Notice. You havethe right to receiveapaper copyofthis Notice.

You mayask us to giveyou a copyofthis Noticeat anytime. Even ifyouhaveagreed to receive this Notice electronically,you arestill entitled to apaper copyofthis Notice.

G. QUESTIONSOR COMPLAINTS.

Ifyou haveanyquestions regardingthis Notice,wish to receiveadditional information about our privacypractices, orwish to filea complaint, please contact ourPrivacyOfficerat (866)484–8876 or byemail at info@viturohealth.com. At the effectivedateofthis policy, ourPrivacyOfficeris Conor Gallagher.Ifyou believeyourprivacyrights havebeen violated,you mayfilea complaint with us or with theSecretaryoftheDepartment ofHealth and Human Services(HHS). To filea complaint with us, obtain the complaint form from ourweb siteor byverbal request and send the complaint form to ourPrivacyOfficerusing oneofthemethods specified below. Regardless ofthemethod ofinitial contact, all complaints must besubmitted in writing. You will not bepenalized for filingacomplaint.